Watson v. Rankin-Thoman, Kinman-Kindell, Co.

2022 Ohio 2811
CourtOhio Court of Appeals
DecidedAugust 12, 2022
DocketE-21-056
StatusPublished
Cited by2 cases

This text of 2022 Ohio 2811 (Watson v. Rankin-Thoman, Kinman-Kindell, Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watson v. Rankin-Thoman, Kinman-Kindell, Co., 2022 Ohio 2811 (Ohio Ct. App. 2022).

Opinion

[Cite as Watson v. Rankin-Thoman, Kinman-Kindell, Co., 2022-Ohio-2811.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT ERIE COUNTY

Stephanie Watson Court of Appeals No. E-21-056

Appellant Trial Court No. 2021 CV 0333

v.

Rankin-Thoman, Kinman- Kindell, Co. DECISION AND JUDGMENT

Appellee Decided: August 12, 2022

*****

Stephanie Watson, Pro se.

David J. Stamolis, for appellee.

ZMUDA, J.

{¶ 1} This matter is before the court upon a pro se appeal of the judgment of the

Erie County Court of Common Pleas, dismissing the matter with prejudice for lack of

subject matter jurisdiction. For the reasons that follow, we reverse and remand the matter

for further proceedings. I. Facts and Procedural Background

{¶ 2} Appellant Stephanie Watson (appellant) resided in an apartment owned by

appellee Rankin-Thoman, Kinman-Kindell, Co. (appellee), in Marion County, Ohio, for

over 13 years. In the beginning of 2020, appellant moved to Erie County.

{¶ 3} On August 27, 2021, appellant filed a complaint in the Erie County Court of

Common Pleas, alleging negligence in maintaining the property, resulting in damage to

her personal property while residing in the apartment she leased from appellee through

the end of 2019. Appellant alleged that appellee failed to address plumbing issues, and

the resulting water damage destroyed or damaged her personal property. Appellant

discarded property that was unsalvageable, and moved the property that might be restored

to her new home in Erie County.

{¶ 4} Appellee filed an answer, raising improper venue and lack of “territorial

subject matter jurisdiction” as defenses. Appellee also asserted a counterclaim, seeking a

monetary judgment for damages allegedly caused by appellant to the subject property, in

excess of her security deposit. Contemporaneously with the answer and counterclaim,

appellee filed a motion to dismiss pursuant to Civ.R. 12(H), or in the alternative, for

change of venue, pursuant to Civ.R. 3(C) and (D), identifying Marion County as the

appropriate venue. As to subject matter jurisdiction, appellee argued the claim arose in

Marion County, and appellant had no contact with Erie County. Appellee’s argument,

relative to venue, was similar. Appellant opposed dismissal or transfer.

2. {¶ 5} On November 18, 2021, the trial court dismissed the matter, with prejudice,

finding “this Court does not have subject matter jurisdiction over these matters.”

{¶ 6} This appeal followed.

II. Assignments of Error

{¶ 7} Appellant articulates the following as error:

The trial court erred by:

[1] granting Defendant’s/Appellee’s Motion to Dismiss for Lack of

Subject Matter Jurisdiction with prejudice over Plaintiff’s/Appellant’s

numerous Motions and Objections specifically under Civil 41 (B) (3) (4),

R.C. Sect. 2305.01 and numerous case law and statutes;

[2] failing to rule on Plaintiff’s/Appellant’s numerous objections and

motions to Defendant’s/Appellee’s pleadings.

We shall address the assignments of error in turn.

III. Analysis

{¶ 8} Appellee sought dismissal for want of subject matter jurisdiction, or in the

alternative, for transfer of venue. The trial court entered a dismissal, with prejudice,

finding a lack of subject matter jurisdiction. We apply de novo review to the trial court’s

decision to dismiss with prejudice. Kostrzewski v. Toledo, 6th Dist. Lucas No. L-14-

1271, 2015-Ohio-2913, ¶ 8, citing Perrysburg Twp. v. Rossford, 103 Ohio St.3d 79,

2004-Ohio-4362, 814 N.E.2d 44, ¶ 5.

3. {¶ 9} “Subject matter jurisdiction is the power of a court to entertain and

adjudicate a particular class of cases.” Bank of Am., N.A. v. Kuchta, 141 Ohio St.3d 75,

2014-Ohio-4275, 21 N.E.3d 1040, ¶ 19, citing Morrison v. Steiner, 32 Ohio St.2d 86, 87,

290 N.E.2d 841 (1972). In contrast, “venue connotes the locality where the suit should

be heard” and is a procedural matter, rather than a jurisdictional concern. Morrison at

87-88.

{¶ 10} The trial court found it lacked subject matter jurisdiction over appellant’s

claim. Courts exercise “only such jurisdiction as is conferred upon them by the

Constitution or by the Legislature acting within its constitutional authority.” Miller v.

State, 147 Ohio App.3d 360, 2001-Ohio-4368, 770 N.E.2d 1052, ¶ 41 (6th Dist.), citing

Humphrys v. Putnam, 172 Ohio St.3d 456, 450, 178 N.E.2d 506 (1961). Subject matter

jurisdiction “is determined without regard to the rights of the individual parties involved

in a particular case.” Kuchta at ¶ 19. “When a court has the constitutional or statutory

power to adjudicate a particular class or type of case, that court has subject-matter

jurisdiction.” Ostanek v. Ostanek, 166 Ohio St.3d 1, 2021-Ohio-2319, 181 N.E.3d 1162,

¶ 2, citing Corder v. Ohio Edison Co., 162 Ohio St.3d 369, 2020-Ohio-5220, 166 N.E.3d

1180, ¶ 14.

{¶ 11} The General Assembly properly defines a court’s subject matter

jurisdiction, as provided at Article IV, Section 4(B) of the Ohio Constitution, and enacted

R.C. 2305.01. Pursuant to the statute, a court of common pleas has original jurisdiction

4. in civil cases in which the amount in controversy exceeds the jurisdiction of the county

courts. Therefore, as appellant’s complaint stated a claim for damages above the

statutory threshold, and the statute grants jurisdiction over such a claim, the trial court

had subject matter jurisdiction over the case. JPMorgan Chase Bank, Natl. Assn. v.

Swan, 6th Dist. Lucas No. L-13-1064, 2014-Ohio-999, ¶ 15.

{¶ 12} In seeking dismissal, appellee argued the trial court lacked subject matter

jurisdiction over the proceeding because the facts alleged demonstrated a claim arising

out of Marion County. Specifically, appellee argued:

Based on the allegations contained in the Complaint filed by the

Plaintiff [appellant] in this action as well as the discussion above, the

Defendant [appellee] did not have any contact within the subject matter

jurisdiction of this Court. Civil Rule 12(H)(3) provides that whenever it

appears by suggestion of the parties the court lacks jurisdiction of the

subject matter, the court shall dismiss the action.

Clearly there is a distinction between subject matter jurisdiction and personal

jurisdiction.1

1 In this appeal, appellee relies on authority relative to dismissal for want of personal jurisdiction as support for affirming the trial court’s subject matter jurisdiction determination, citing to Hunter v. Rhino Shield, 2018-Ohio-2371, 155 N.E.3d 22 (10th Dist.). Appellee otherwise cites to case law regarding jurisdiction to hear an administrative appeal, which has no application to the present matter. See Huntsman v. State, 5th Dist. Stark No. 2016CA00206, 2017-Ohio-2622.

5. {¶ 13} Subject matter jurisdiction concerns the authority of the court, and may not

be waived. In re Burton S., 136 Ohio App.3d 386, 391, 736 N.E.2d 928 (6th Dist.1999).

Appellant invoked the subject matter jurisdiction of the trial court by filing her complaint.

(Citation omitted.) Id. Personal jurisdiction, on the other hand, is obtained through

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Booker v. RSH 506, L.L.C.
2025 Ohio 1375 (Ohio Court of Appeals, 2025)
Williams v. MJS Ents., Ltd.
2022 Ohio 3695 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2022 Ohio 2811, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-v-rankin-thoman-kinman-kindell-co-ohioctapp-2022.